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Germany - Arm’s Length Nature of a Transfer Price as the Decisive Criterion for Compliance with the Arm’s Length Principle (Not Only) in Treaty Cases

Country:
Germany
Author:
U. Andresen; D. Kerenyi
Issue:
International Transfer Pricing Journal, 2013 (Volume 20), No 3
Published:
6 May 2013
A recent decision of the Federal Tax Court concerned the blocking effect of article 9 of the OECD Model and its derivatives over the special conditions developed in prior jurisprudence of the Federal Tax Court.
 
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